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Morocco – Implementation of UBO Regulation
Earlier this year, the Public Register of Beneficial Owners of Moroccan Companies and legal structures (RBO) electric platform was launched.
Whilst legislation regarding Ultimate Beneficial Ownership (UBO) identification has been in place in Morocco since September 2021 (Decree no. 2.21.708), entities were not required to take any action until the launch of the RBO electronic platform.
With the platform now live, all companies with legal entities in Morocco must comply with local UBO obligations immediately.
For newly incorporated entities the deadline is within one month of the date of registration in the trade register.
What are the requirements?
Legal entities must keep correct and up-to-date records for their UBOs. This includes gathering information such as the UBO’s name, date of birth, nationality, residence, and the nature of their involvement with the company.
The deadline for reporting changes is one month from the date of any change impacting information on firms or their beneficial owners.
Who qualifies as a UBO?
The regulation identifies a UBO as a natural person holding 25% or more of a company’s shares or voting rights.
If no individual satisfies the 25% criterion, the persons in charge of the legal entity’s management are designated as the UBOs.
The risk of non-compliance
Non-compliance with Morocco’s UBO regulation can result in fines and administrative sanctions. Entities that fail to register their UBO information or submit false information may face punitive measures. Directors and officers of non-compliant entities can also be held personally liable.
